Motorola Mobility, Inc. v. Apple, Inc.

Filing 205

Plaintiff's MOTION to Amend/Correct 88 Order on Motion for Miscellaneous Relief the Procedural Schedule to Serve Supplemental Invalidity Contentions, Accompanying Memorandum of Law in Support and Declaration of Cathleen Garrigan in Support Thereof by Motorola Mobility, Inc.. Responses due by 1/6/2012 (Attachments: # 1 Declaration of Cathleen Garrigan, # 2 Exhibit A to Declaration of Cathleen Garrigan, # 3 Exhibit B to Declaration of Cathleen Garrigan, # 4 Exhibit C to Declaration of Cathleen Garrigan, # 5 Exhibit D to Declaration of Cathleen Garrigan, # 6 Exhibit E to Declaration of Cathleen Garrigan, # 7 Exhibit F to Declaration of Cathleen Garrigan, # 8 Exhibit G to Declaration of Cathleen Garrigan, # 9 Exhibit H to Declaration of Cathleen Garrigan, # 10 Exhibit I to Declaration of Cathleen Garrigan, # 11 Exhibit J to Declaration of Cathleen Garrigan, # 12 Exhibit K to Declaration of Cathleen Garrigan, # 13 Exhibit L to Declaration of Cathleen Garrigan, # 14 Exhibit M to Declaration of Cathleen Garrigan, # 15 Exhibit N to Declaration of Cathleen Garrigan)(Mullins, Edward)

quinn emanuel

trial lawyers | los angeles

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September 1, 2011
VIA E-MAIL
Christine Haskett, Esq.
Covington & Burling LLP
One Front Street
San Francisco, CA 94111-5356
Re:

Jill Ho, Esq.
Weil, Gotshal & Manges LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065

Motorola et al. v. Apple

Dear Christine and Jill:
I write to request the supplementation of Apple's production in the S.D. Florida matter (Case No.
1:10-cv-023580).
Apple has asserted EP 1 964 022 ("EP 022") – the European counterpart of U.S. Patent No.
7,657,849 – against various Samsung Electronics entities in the Netherlands. As you are no
doubt aware, on August 24, the Dutch Court issued an Order denying Apple's requested relief
with respect to EP 022 because "there is a reasonable chance that EP 022…will be considered
invalid" after a full trial on the merits.
The prior art cited by Samsung, the Court's opinion, and all documents concerning the litigation
of EP 022 are relevant to this action and responsive to several of Motorola's Requests for
Production, including but not limited to Request Nos. 2, 15, 16, 18, 28, 36, 37, and 41.

quinn emanuel urquhart & sullivan, llp
NEW YORK | 51 Madison Avenue, 22nd Floor, New York, NY 10010 | TEL [phone] FAX [phone]
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TOKYO | Akasaka Twin Tower Main Bldg., 6th Fl., 17-22 Akasaka 2-Chome, Minato-ku, Tokyo 107-0052 Japan | TEL [phone] FAX [phone]

Please immediately produce all documents referring or relating to all litigations concerning EP
022 or related patents, including but not limited to the Dutch Court's August 24, 2011 decision in
Case Nos. 396957 / KG ZA 11-730 and 396959 / KG ZA 11-731, the prior art relied upon by the
Court, and any other prior art produced by Samsung relating to EP 022.
Very truly yours,
/s/ Matthew O. Korhonen
Matthew O. Korhonen

02426.51753/4324197.1

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